Responding to Auditors’ Requests When Facing FCPA Allegations

One of the issues that a company investigating an FCPA matter must face is whether and how to disclose the investigation in its financial statements. This challenge will often arise in the context of the company’s annual audit, when the company’s attorneys are asked about pending and threatened claims. A recent Strafford program provided an in-depth treatment of requests by auditors for information about potential claims and liabilities and best practices for attorneys responding to those requests. The program featured Maryann A. Waryjas, senior vice president, chief legal officer and secretary of Herc Rentals; Stanley Keller, of counsel at Locke Lord; Brian E. Kowalski, a partner at Latham & Watkins; and Alan J. Wilson, an associate at WilmerHale. See also “Experts from PwC Discuss Compliance Audits and Common Missteps” (Sep. 28, 2016).

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